The defandant’s re-posting of an entire news article to educate the public is transformative from the current copyright holder’s use, which is “nothing more than litigation-driven.” Thus, the court said, the defendant’s use “does not constitute a substitution for plaintiff’s use.” (The court did note, however, that the former copyright owner did use the article for news-reporting purposes.)The purpose of the use was non-commercial because the defendant was an educational, non-profit organization.The purpose of the news article is informational and thus the work entitled to less copyright protection than a “creative work of entertainment.”The use of the entire article was reasonable because the purpose was to educate the public and the factual nature of the information made it “impracticable” to cut the article or edit it down.No market harm was demonstrated by the plaintiff.